Wastes Generated from the Exploration, Development, and Production of Crude Oil, Natural Gas, & Geothermal that are NOT Excluded from Regulation as a Hazardous Waste

Many wastes generated during the exploration, development, and production of crude oil, natural gas, and geothermal (E&P Wastes) are excluded from regulation as a hazardous waste pursuant to a RCRA conditional exclusion at 40 CFR 261.4(b)(5). While an earlier article listed examples of wastes generated by the crude oil, natural gas, and geothermal industry during their exploration, production, and development that are excluded from regulation as hazardous waste, there are other wastes from the same industries and similar processes that are not excluded. A list of some examples of non-exempt E&P Wastes follows:

Remember: Just because a waste is generated by the exploration, development, and production of crude oil, geothermal, or natural gas does not mean it is excluded from regulation as a hazardous waste

These wastes – unless excluded elsewhere or not meeting the definition of a listed or characteristic hazardous waste – must be managed as a hazardous waste. Or, as in the case of the Radioactive tracer wastes, they may be managed under regulations other than those of the Resource Conservation and Recovery Act (RCRA).

The generation of a hazardous waste, depending on your hazardous waste generator status may require you to provide initial and annual training for all facility personnel who require knowledge of the regulations in order to complete their job duties. I provide this training. Contact me for a free training consultation.

Good training can prevent fines and ensure compliance with all Federal and State regulations.